Building Energy Codes

Commercial Code Change Proposals for the 2015 IECC

This page provides archival documentation relative to DOE participation in the 2015 IECC. For official results, visit the ICC web site.

DOE Proposals for the IECC

The U.S. Department of Energy (DOE) supports the International Energy Conservation Code (IECC) by participating in the code development process administered by the International Code Council (ICC). As a participant in this process, DOE considers and evaluates concepts to be submitted as proposed changes to the IECC ("code").

DOE participates in the IECC development process by:

Developing code change proposals for submission to the ICC

Gathering public input on DOE code change proposals from interested parties prior to submitting to the ICC

A Notice is published in the Federal Register further outlining DOE participation in the ICC code development process. Interested stakeholders may also choose to receive updates on DOE code development activities.

DOE Proposal Development

DOE seeks to advance energy efficiency in the IECC by strengthening the code where cost-effective, and improving the criteria to be more easily understood, applied, implemented and enforced. Prior to submitting proposed code changes ("proposals") to the ICC, DOE publishes draft proposals that it has developed, along with documentation of concepts, for public review and comment. DOE will not provide responses to individual comments, but will consider any and all comments timely submitted in developing final proposals. DOE draft proposals, along with additional concepts still under consideration, are further developed based on stakeholder feedback received. Final proposals are posted for public viewing prior to submitting to the ICC.

Submitting Comments on DOE Proposals

In the current code cycle, the ICC will be considering revisions to the 2012 IECC which will result in the 2015 IECC. In order to allow adequate time to incorporate feedback prior to the ICC submission deadline, interested parties are asked to submit any and all comments on DOE initial concepts, draft code change proposals, and public comments by the deadlines specified below. Early feedback is appreciated in order to maximize the opportunity for revisions and enhancements.

All submissions received must include the agency name (U.S. DOE), docket number (EERE-2012-BT-BC-0030), and any/all applicable DOE concept numbers or ICC reference numbers (see table below) in the subject line of the message.

DOE Technical Analysis

In developing proposals for submission to the ICC, DOE conducts a series of analyses to evaluate energy savings and economic impacts of its potential revisions, as applicable. However, many proposals submitted to the ICC do not require analysis as they represent minor corrections or alignments between the code language itself, or referenced standards, changes to the format of the code, or have no cost impact. Where appropriate, DOE conducts life cycle cost analysis as described in Commercial Energy and Cost Analysis Methodology. DOE is not able to provide technical assistance at the request of outside parties, but reserves the right to conduct analysis in support of proposals DOE is considering for submission to the ICC. While DOE cannot enter into joint proposals (outside of proposals submitted jointly with another federal agency), DOE supports efficiency proposals from the perspective of its own analysis.

DOE references all analysis and supporting documentation as required by the ICC. Analysis performed by DOE or its contractors for the purpose of developing proposals should be considered on a technical basis, and does not represent an endorsement of any particular individual or organization. DOE also publishes the results of its analysis, along with supporting energy simulation models, for review and use by outside parties. Any interested party wishing to review or build-upon the DOE analysis can access it via Development.

DOE Participation in the ICC Code Development Hearings

At ICC hearings, DOE communicates its opinion on proposals as follows: DOE will defend its proposals. To the extent that DOE has prepared a technical analysis of a proposal other than a DOE proposal, consistent with the discussion above, DOE may present the results of the analysis. Again, presentation of technical reviews does not constitute an endorsement of any proposal. DOE may also recognize a proposal to the extent that the proposal or provisions within the proposal are the same as a DOE proposal or provisions within a DOE proposal. DOE may alter its proposal based on information it obtains at the code hearings and may publish amendments to its proposals for public review and comment at: Development. Final amendments to DOE proposals are posted at the same web address for public viewing prior to submitting to the ICC.

Ex Parte Communications

DOE anticipates that it or its contractors may be contacted regarding code concepts, ideas or change proposals through phone, mail, or email. While DOE code change proposals to the IECC are not regulations, DOE will follow ex parte communication policy for such communications. Guidance on ex parte communications was published on January 21, 2009 (74 FR 4685). Note that such communications will be reflected in the public docket consistent with the ex parte guidance.

The final proposals linked from this page are as submitted to ICC. In some cases the proposals have been modified in the ICC process, and official proposals can be viewed at the ICC website. The order in which the proposals are presented should not be construed to represent any prioritization of the proposals.

Where a formal analysis is not required, notes rather than a link are provided in the analysis column. Draft and final proposals, as well as supporting analysis files, are added as they become available.

Also note that proposals that would extract criteria from American Society of Heating, Refrigerating, and Air-conditioning Engineers / Illuminating Engineers Society (ASHRAE/IES) 90.1-2010 or any published addenda to that standard would be addressed by ASHRAE pursuant to procedures that guide ASHRAE involvement in development of model codes and standards.

Draft and final proposals are available to view/download as separate individual files from the tables below, or as a complete package:

Commission the Entire Building (C408). Increase commissioning scope beyond Heating, Ventilation and Air Conditioning (HVAC) and lighting to also include the building envelope and service water heating systems, and provide detailed provisions for each of them. Develop a simplified process for buildings under 25,000 square feet in floor area. Include provisions to allow for building commissioning compliance verification to be performed through special inspections using approved third parties.

None

N/A

N/A

N/A

N/A

CA-5b(CE284)

Commission Service Water Heating (C408). Increase HVAC commissioning scope to also include the building service water heating systems.

Commercial Complex HVAC Systems to meet ASHRAE/IES 90.1 (C403.4)Replace all of the IECC commercial complex HVAC system provisions with a reference to ASHRAE/IES 90.1 Section 6. Simple system prescriptive and mandatory requirements will remain in the IECC.

Reference Appendix G from ASHRAE/IES 90.1 as Performance Path (C401.2/C407). Replace Section C407 with a singular reference to ASHRAE/IES 90.1 for the criteria applicable to the performance path to compliance, and require compliance be based on a 26% reduction in energy cost for the proposed design over the standard design building.

Increase Scope for Additions and Alterations (C101.4.3). Increase the scope of what must meet the provisions of the IECC for additions, rehabilitations, renovations or repairs (e.g., reducing the exceptions in that area).

Multifamily Residential Classification (C101 and C202). Revise the definition of residential building so only attached and detached one and two family dwellings and townhouses are considered residential, and all others commercial.

None

N/A

N/A

N/A

N/A

CA-15

Small Simple Building Compliance Path (C402). Develop a simplified approach for envelope, mechanical, service water heating, and lighting that will apply to small simple buildings.

Water Heating. (C404). Require use of more efficient service water heating, including solar, heat recovery, condensing water heater, or heat pump water heaters for buildings with significant hot water usage (e.g., hospitals, restaurants, dormitories, hotels, laundries, fitness centers, apartment buildings). Consider system size, system efficiency, etc. as part of the proposal. Include alternative path for point-of-use water heating sources for low use fixtures that provide hot water (e.g., lavatory sinks).

Eliminate Distinction Between Simple and Complex HVAC Systems. Without changing requirements, removes the distinction between simple and complex systems and presents prescriptive HVAC requirements all together. This proposal was disapproved by committee, but approved by floor action. It will cause an unintended weakening of economizer requirements and undoes an economizer clarification in DOE’s approved proposal CE249. This comment applies the corrective language from CE249 to CE241.

Limited Application of Air-Cooled Chillers. (C403.4.8 new). Require buildings with 300 tons or greater peak cooling load to have no more than 100 tons served by air-cooled systems. Include exceptions for high-efficiency air-cooled systems and systems with thermal storage.

Application of Fenestration Provisions (C202). Clarify application of thermal provisions (U-factor or SHGC) for fenestration materials or products installed at an angle greater than 0 up to and including 30 degrees from vertical.

Below-Grade Wall Insulation (C402.2.4). Clarify how insulation is to be installed and how deep. The term "installed in or continuously on" is potentially confusing in that it infers that the insulation could be inside the wall but not necessarily continuous. Also clarify where the depth of burial measurements are to be made.

Radiant Heating Panel Insulation (C402.2.8). Clarify that panels installed in building thermal envelope assemblies must be insulated per the requirements of the assembly in which they are installed. Require insulation of at least R-3.5 on the non-radiant surface when installed in interior assemblies. Refer to the other applicable sections of the code for insulating heated slabs.

Access Doors and Openings (C402.4.4). Clarify the components covered are subject to air leakage provisions as components of the building thermal envelope, and provide a distinction between these doors and other doors that are already covered within the scope of fenestration assemblies.

Equipment and System Sizing (C403.2.2). Delete the words "and system" from the title as the provisions are written to apply to the output capacity of the equipment that provides heating or cooling functions.

Low-Pressure Duct Systems (C403.2.7.1.1). Clarify that continuously welded and locked construction methods for duct systems meets the code, and delete text indicating what must be provided on the drawings because that is already covered in C103.2.

Acceptance of Commissioning Report (C408.2.4.1). Revise the commissioning provision so that buildings cannot be considered for a final inspection (do not pass the mechanical inspection) until the owner indicates in writing they have the required commissioning report.

Repair Energy Requirements (403.1). Requires equipment installed during repairs to meet the provisions of the IECC and insulation to be upgraded to current IECC requirements when structural components are exposed.

Performance Path (1401.5 & 1401.6). Exempt upgrade of alterations, additions, changes in occupancy, or repairs to meet the provisions of the 2012 IECC when a registered design professional documents energy performance in conformance to the IECC performance provisions.